Kelly A. Lenahan-Pfahlert | lenahanpfahlertk@ballardspahr.com |  215.864.7311 | view full bio

Kelly focuses her practice on white collar defense and complex civil litigation.  Kelly has substantial experience in litigating BSA/AML issues on behalf of financial institutions relating to both discovery and liability, assisting with AML-related internal investigations

President Trump’s May 19, 2026 executive order, Restoring Integrity to America’s Financial System, directs Treasury, FinCEN, the CFPB, and the federal banking agencies to reassess how financial institutions identify and manage risks associated with non-work authorized populations and related cross border financial activity. The order reflects a significant shift in federal expectations across

President Trump issued Executive Order 14405 (the “Order”) on May 19, 2026 titled Integrating Financial Technology Innovation into Regulatory Frameworks. The Order directs federal financial regulators to review and update regulations, guidance, and supervisory practices to support financial technology innovation and reduce barriers to entry for non‑bank fintech firms. It follows earlier actions establishing

Last month, the U.S. Department of the Treasury announced a new cybersecurity information‑sharing initiative led by its Office of Cybersecurity and Critical Infrastructure Protection (OCCIP). The program is designed to give eligible U.S. digital asset firms access to the same actionable cyber‑threat information Treasury already provides to traditional financial institutions. According to Treasury, the effort

On April 8, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) issued a joint Notice of Proposed Rulemaking (NPRM) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The proposal would create a comprehensive anti‑money‑laundering/countering‑the‑financing‑of‑terrorism (AML/CFT) and sanctions compliance

As part of the U.S. Department of Treasury’s efforts to modernize the U.S. anti-money laundering regulatory and supervisory framework, the Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would reform how financial institutions design and operate their anti-money laundering and countering the financing of terrorism (AML/CFT) programs. Though not a wholesale rebuild

The U.S. Department of the Treasury has issued its first proposed rule under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, marking a key milestone in federal efforts to regulate payment stablecoins. The Notice of Proposed Rulemaking (NPRM) outlines the principles Treasury will use to assess whether a state’s regulatory regime is

On March 10, 2026, FinCEN issued a renewed and expanded Geographic Targeting Order (GTO) imposing enhanced reporting and recordkeeping requirements on certain money services businesses (MSBs) operating along the Southwest border. According to FinCEN, the action is intended to support law enforcement efforts to disrupt money laundering and bulk‑cash movement tied to Mexico‑based drug cartels

In 2025, the Nevada Gaming Commission (Commission) and the Nevada Gaming Control Board (NGCB) launched one of the most significant enforcement waves in state history, imposing nearly $27 million in fines against three of the Las Vegas Strip’s largest operators: Caesars Entertainment, MGM Resorts, and Resorts World Las Vegas. Each case centered on failures to

The prosecution of the developers behind Samourai Wallet illustrates how U.S. authorities are broadening their approach to privacy‑focused cryptocurrency tools. In April 2024, the U.S. Attorney’s Office for the Southern District of New York announced charges against Keonne Rodriguez, Samourai’s chief executive, and William Lonergan Hill, its chief technology officer. The indictment alleged that Samourai

On October 9, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a renewal of its Geographic Targeting Order (“GTOs”), which require U.S. title insurance companies, including their subsidiaries and agents, to collect, retain, and report specified information regarding certain non-financed residential real estate transactions involving legal entities. The new GTO is effective from October 10